ML20063E521

Supplemental Answer to Second Set of Interrogatories. Certificate of Svc Encl

ML20063E521
Person / Time
Site:	Perry
Issue date:	08/26/1982
From:	Willmore R CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	OHIO CITIZENS FOR RESPONSIBLE ENERGY
References
NUDOCS 8208300287
Download: ML20063E521 (5)

Text

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g o' August 26, 1982 00CKETED USHRC UNITED STATES OF AMERICA 2 AG3274034 NUCLEAR REGULATORY COMMISSION gICE SEC -

Before the Atomic Safety and Licensing Board 00ASCH In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Now. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' SUPPLEMENTAL ANSWER TO OHIO CITIZENS FOR RESPONSIBLE ENERGY SECOND SET OF INTERROGATORIES TO APPLICANTS Applicants, in their answers to Ohio Citizens for Responsible Energy ("OC RE" ) Second Set of Interrogatories to Applicants, dated April 29, 1982, were unable to Answer Interrogatory #2-14 because they did not have the document referenced in the Interrogatory.

OCRE now has supplied ti ce document, and Applicants make the follow-ing response:

2-14. Is operability of the Hi-Level scram independent of SDV venting or draining requirements as recommended in the 8/1/80 letter from Michelson (AEOD) to H. Denton (Office of NRR, NRC)?

Response

Yes, the operability is independent. The scram discharge instrument volume (SDIV) is connected directly to the low point of the scram discharge volume piping, as recommended in the 8/1/80 letter from Michelson (AEOD) to H. Denton (Office of the 8208300287 820826 PDR ADOCK 05000440 O PDR )

NRR, NRC). Furthermore, each of the two separate instrument volumes has fully redundant instrumentation for the purpose of initiating scram on high SDIV water level.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE r

By:

Jay E. Silberg, P.C.

Robert L. Willmore Counsel for Applicants 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: August 26, 1982 j

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AFFIDAVIT STATE OF CALIFORNIA ) ss:

COUNTY OF SANTA CLARA)

MONTY A. ROSS, being duly sworn, deposes ar.d says:

That he is Manager, Control Room Systems Design of General Electric Company and that the facts set forth in the foregoing applicants answer to Ohio Citizens for Responsible Energy Interrogatory 2-14 (Issue #5) dated June 25, 1982, are true and correct to the best of his knowledge, information and belief.

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MONTY 4. ROSS Subscribed and sworn to before me on this 24 da) of August, 1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t

i Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docuet Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Supplemental Answer To Ohio Citizens For Responsible Energy Second Set of Interrogatories To Applicants," were served by deposit in the U.S. Mail, First Class, postage prepaid, this 26th day of August, 1982, to all those on the attached Service List.

Robert L. Willmore Dated: August 26, 1982 l

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-,- 1 j NUCLEAR REGULATORY COMMISSION

Before the Atomic Safety and Licensing Board In the Matter of )

)

1THE CLEVELAND ELECTRIC ) Docket Nos. 50-440

' ILLUMINATING COMPANY, e_ t_ a l . )

. 50-441

)

(Perry Nuclear Power Plant, )

Units ~1 and 2 )

SERVICE LIST ,

Peter B. Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Board Office'of the Secretary U.S. Nuclear Regulatory Commission U'.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Frederick J. Shon Stephen H'. Lewis, Esquire .

Atomic Safety and Licensing Board Office of the Executive U.S. Nuclear Regulatory Commission Legal Director Wahsington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt Appeal Board OCRE Interim Representative U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D. C. 20555 Mentor, Ohio 44060 Daniel D. Wilt, Esquire Dr. John H. Buck Atomic Safety and Licensing P. O. Box 08159 Appeal Board Cleveland, Ohio 44108 l

l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Donald T. Ezzone, Esquire Assistant Prosecuting Attorney Gary J. Edles, Esquire Lake County Administration Center Atomic Safety and Licensing 105 Center Street Appeal Board Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission

-Washington, D.C. 20555 .

John G. Cardinal, Esquire Prosecuting Attorney Atcmic Safety and Licensing Ashtabula County Courthouse Board Panel Jefferson, Ohio 44047 U.S. Suclear Regulatory Commission Washington, D.C. 20555 Terry Lodge, Esquire 915 Spitzer Building Toledo, Ohio 43604